Inman-Poulsen Lumber Co. v. Commissioner of Internal Revenue

POPE, Circuit Judge.

The respondent Commissioner made a determination of a deficiency in the income taxes of the petitioner, here called the Company, for the calendar year 1944. The portion of the deficiency here in dispute arises out of the Commissioner’s disallowance of a deduction in the amount of $47,368.76 which the Company claimed on account of an alleged debt to it which it asserted became worthless in that year. Petitioner sought a redetermination of the deficiency before the Tax Court on the ground that its deduction was allowable under § 23 (k) of the Internal Revenue Code. 1

The Tax…